In February 2026, the New York State Senate passed the Climate Corporate Data Accountability Act (CCDAA), a proposed law that would require large companies doing business in New York to publicly disclose their greenhouse gas emissions.
Modeled closely on California's SB 253, the CCDAA would apply to businesses with over $1 billion in annual revenue and require annual disclosures of Scope 1, 2, and 3 emissions from 2028.
The bill passed the Senate 40-22 on February 10, 2026, and is now before the Assembly Codes Committee. It still needs to clear a full Assembly vote and receive Governor Hochul's signature before becoming law. A decision is expected by June 2026.
This guide covers:
- The current status of the CCDAA and what companies should watch for
- Which companies would be in scope
- What emissions disclosures the CCDAA would require and when
- Assurance requirements under the bill
- Penalties and enforcement provisions
What is the current status of the CCDAA?
The CCDAA is a proposed law, not yet in force. As of April 2026, the bill has passed the New York Senate and is under review by the Assembly Codes Committee. The committee has discretion over when—or whether—it reviews the bill this legislative session. If the bill does not pass the Assembly this year, it would need to be reintroduced next session.
If the bill clears the Assembly, Governor Hochul would have 10 days to sign or veto it. A final decision is expected by June 2026.
Who would be in scope for the CCDAA?
The CCDAA would apply to partnerships, corporations, LLCs, and other business entities that meet both of the following criteria:
- Do business in New York State and derive receipts from activity in the state; and
- Have total annual revenues exceeding $1 billion in the preceding fiscal year, including revenues from all subsidiaries doing business in the state. This intentionally mirrors the threshold in California’s own emissions laws.
What does "doing business in New York" mean?
"Doing business" follows the definition in Section 209 of New York's Tax Code. Companies should check with their finance teams to confirm their status. In practice, a company is also considered to "derive receipts" from New York if it earns more than $1 million in the state in a taxable year.
When would reporting begin?
Emissions scope | First reporting year | Data covered |
|---|---|---|
Scope 1 & 2 | 2028 | FY 2027 |
Scope 3 | 2029 | FY 2028 |
Annual reporting would continue thereafter.
What would complying with the CCDAA require?
In-scope companies would be required to disclose Scope 1, 2, and 3 greenhouse gas emissions annually. Disclosures must follow the GHG Protocol (GHGP). No additional methodology requirements are currently specified in the bill. Watershed is monitoring whether any requirements from New York's existing facility-level disclosure regulation (6 NYCRR Part 253, which requires specific methodologies) are incorporated into the CCDAA.
Reports would be submitted to a yet-to-be-set-up “Emissions Reporting Organization”. The bill contains proposals for how this organization would operate. Specific submission deadlines have not yet been defined.
Do CCDAA disclosures require assurance?
Yes, the bill includes a phased assurance framework.
Scope | Limited assurance begins | Reasonable assurance begins |
|---|---|---|
Scope 1 & 2 | 2027 | 2031 |
Scope 3 | 2032 (if required) | TBD |
For Scope 3, the Department of Environmental Conservation (the designated administrator in the bill) must review and potentially establish assurance requirements by January 1, 2028.
Assurance providers must be independent third parties with significant experience in measuring, analyzing, reporting, or attesting to GHG emissions.
Are there penalties for non-compliance?
Yes. Companies that willfully fail to comply face penalties of up to $100,000 per day, with a maximum of $500,000 per reporting year. Penalties take into account a company's compliance history and good faith efforts.
In-scope companies would also be required to pay fees to the DEC to administer the program; the fee amounts have not yet been proposed.
Safe harbor for Scope 3 disclosures
The bill includes an important protection for Scope 3 reporting: companies cannot be penalized for misstatements about Scope 3 emissions if those statements were "made with a reasonable basis and disclosed in good faith." Additionally, for Scope 3 reporting between 2028 and 2031, penalties only apply for non-filing, not for errors in the disclosed figures.
What's next?
The CCDAA is still moving through the legislative process, and companies should track developments through mid-2026. Even if the bill does not pass this session, policy developments across several states in the US (California, New Jersey, Illinois) as in California point toward eventual mandatory emissions disclosure for large businesses.
How Watershed can help
Companies that act now—measuring and managing emissions before the law takes effect—won't be scrambling to comply later. Here's where to start:
- Set up scope 1, 2, and 3 emissions calculations that are automated, repeatable, and can be disaggregated for regulatory reporting
- Prepare for assurance with transparent, auditable data
- Build a decarbonization plan that goes beyond compliance
Watershed can help with all of the above.
Note: This guide reflects the CCDAA as passed by the New York Senate in February 2026. The bill is not yet law. Watershed will update this page as the legislation progresses.
